Wednesday, October 14, 2026

security.txt: 1.25% Have One

Every company that sells software or a connected device should be legally required to publish where a stranger can report a security bug, and to promise someone will read it. The cheapest form is a plain text file called security.txt, and only 1.25% of the top million domains have one, per a URIports scan on 24 January 2025. On roughly 98 of every 100 big sites, a researcher who spots a hole has nowhere to send it.

Poster on security.txt showing a laptop with cracked padlock beside an empty letterbox

TL;DR: a published, monitored channel for security reports should be compulsory, and the rule must demand a reply, not just a file.

  • The UK has required device makers to publish a reporting contact and reply timings since 29 April 2024.
  • The EU requires a published disclosure policy from 11 December 2027; the US binds only its own agencies.
  • A listed address that bounces helps nobody, so test your own channel.
  • Write the rule around an answer, not around a file.

Why should security.txt be compulsory?

A security bug report is only useful if the right person receives it, so a public, monitored contact turns a stranger's warning into a fix, while a voluntary one leaves most sites silent.

The format is simple. RFC 9116, the 2022 internet standard for the file, asks for a contact, an expiry date and an optional policy link. The CRA's 24-hour reporting duty assumes a vendor hears about the bug first: before a vendor can tell regulators within a day, someone has to be able to tell the vendor.

Neef, Schlunke (TU Berlin) and Hennig (KIT), in a paper posted to arXiv in June 2026, tracked the 40 largest German listed firms from 2023 to January 2025: adoption of the file or a formal disclosure programme went from half the group to nearly all of it. One country, 40 firms and no proof of cause, but firms plainly move when a deadline is visible.

Voluntary effort is not nothing. By my arithmetic from URIports' two scans, domains with the file rose from 6,816 in April 2024 to 12,510 in January 2025, roughly 84% in nine months. I still disagree that good practice will spread alone: most sites stay silent and attackers do not wait. The UK wrote the duty into law with its default-password ban for connected devices instead of hoping.

Four figures test whether a bare file does the job: the European Commission's CRA page sets the dates, the TU Berlin and KIT paper sampled security mailboxes, and URIports checked the files themselves.

Months between two EU duties

15 months

Vendors report out before listening

Big German firms with a channel

37 of 40

Large firms moved; small unknown

Listed security inboxes that bounced

46%

A listed address may be dead

Files that follow the standard

44%

Most files fail the standard

The bounce figure is the one I would show a regulator. The sample was small, 26 generic security addresses, so it is a warning light rather than a rate. Still, a finder whose email errors out has done everything asked; the failure sits with the company, and only a duty to acknowledge, as UK law now sets, closes it.

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An address that bounces is a promise nobody keeps. The law should demand an answer, not just an address.

Is a vulnerability disclosure policy required by law?

It depends on where you sell: UK law already requires consumer-device makers to publish a reporting contact, EU law will require a coordinated disclosure policy from December 2027, and US federal law requires it only of agencies.

Schedule 1, paragraph 2 of SI 2023/1007 makes the UK maker of a relevant connectable product publish a contact plus timings for acknowledgement and status updates, free and in English (as of 2024). The EU's Cyber Resilience Act, Regulation 2024/2847, requires in Annex I, Part II, point 5 a policy on coordinated vulnerability disclosure; the European Commission's CRA page gives the dates (checked 14 October 2026). CISA's Binding Operational Directive 20-01 applies the idea to US federal agencies only (as of 2020).

Category Detail What it means
⚖️ UK rule Live since 29 Apr 2024: contact plus reply timings ✅ Buyers can demand a reply
⚖️ EU rule Reporting out from 11 Sep 2026, policy from 11 Dec 2027 ⚠️ The listening duty comes last
⚖️ US rule Federal agencies only, since 2 Sep 2020 ❌ Their suppliers are not bound
⏱ Reply clock CISA suggests: acknowledge in 3 business days, assess in 7, resolve in 90 ⚠️ A benchmark, not a legal limit
🔒 Safe harbour Agencies must not pursue good-faith finders ✅ Finders can speak without fear
🛠 Quick test Email your own security address ✅ One email proves it works

The UK and EU put the duty on the people who profit from the product; the US puts it on its own civil servants and leaves the vendors it buys from to volunteer. My view: that is backwards, because unanswered reports pile up in the market, not in one agency's inbox.

2 Sep 2020. US agencies. 29 Apr 2024. UK devices. 11 Sep 2026. EU reporting. 11 Dec 2027. EU full duty.

Where you sell decides whether a public reporting channel is already your legal duty. Source: CISA BOD 20-01, SI 2023/1007 and the European Commission's CRA page.

What goes wrong when a file is all you ask for?

A file proves only that someone typed a few lines once: a published, unmaintained one can point to nobody, which is why the rule must demand a working, answered channel rather than a text file.

RFC 9116 makes the expiry date a required field, yet URIports found 45% of files carry no Expires line and another 13% had already expired. Fewer than half follow the standard, so by my arithmetic roughly one top-million domain in 180 publishes a file that does; that is derived from two published rates, not a URIports figure. The objection that a file is cheap theatre is half right. Call it a file, then correct that: the file was never the point, the reply is.

The other objection is that a mandate would bury small firms. The UK text is gentler than critics assume: it asks when a reporter can expect an acknowledgement and updates, not a deadline for the fix. Whether a one-person shop should carry the same duty as a listed company is the real grey area; in my opinion, yes to acknowledging, no to fixing on a clock. Voluntary targets end badly: the CISA and FBI memory-safety roadmap set a 1 January 2026 date that binds nobody. Watch for these in your own setup:

  • An empty Expires field or a lapsed date.
  • A security address routed into a general support queue.
  • No named owner, so the reply is nobody's job.
  • A policy that threatens finders into silence.

Check which of these is true for you

  • You sell a connected device to UK shoppers and your site never says how to report a flaw.
  • Mail to your security address lands in a shared queue someone else triages.
  • Your file's expiry date has passed, or nobody owns the renewal.
  • A researcher writing to you has no written promise you will not sue.

The decision is whether to wait for the law or run a monitored channel now, and the answer is now. This week, email your own security address from a personal account and time the reply: a bounce or silence tells you what to fix first.

Wednesday, October 7, 2026

Default Password Ban: Why Labels Fail

Every router, camera and smart plug sold in the United States should be legally required to carry a password unique to that unit, or make you set your own, before it touches your Wi-Fi. Britain has enforced exactly that default password ban since 29 April 2024. America chose a sticker. The standard objection says a voluntary label lets shoppers reward careful makers without Washington writing firmware rules. It sounds reasonable, until you see what the sticker has done since.

Infographic arguing for a default password ban, with a router and an open padlock

Key Takeaways: a ban works because it covers every box on the shelf; a voluntary label covers only the makers who choose to apply.

  • British buyers get unique or user-set passwords on smart devices by law, no label needed.
  • The US label is optional, so a maker that skips it loses nothing but a sticker.
  • California and Oregon prove makers can comply, so a federal rule mostly extends firmware they already ship.
  • Until Washington acts, check for a unique or set-your-own password before you buy.

Why a default password ban beats a label

A ban beats a label because it protects the buyer who never reads packaging, never registers the device and never changes a setting, while a label protects only the shopper who already knows to look for it.

The British version, set out on GOV.UK's product security regime page, is blunt: passwords must be unique per product or set by the user. Makers must also publish a route for reporting security bugs and say how long they will ship security updates. A British buyer gets that protection without knowing the law exists, which is the whole point of a rule.

America took the other road. The FCC approved the US Cyber Trust Mark on 14 March 2024 as a voluntary label, CyberScoop reported, so a US shopper gets password protection only when a maker opts in. Its lead administrator, UL Solutions, then withdrew on 19 December 2025 amid an FCC probe into its China ties, says Cybersecurity Dive. The FCC named the ioXt Alliance in its place on 13 April 2026, Broadband Breakfast reported, and won't pay for the job. By my count, the label shoppers were told to trust sat with nobody in charge for nearly four months.

Washington has been here before: its memory safety roadmap deadline for critical-infrastructure software carried no penalty and passed quietly. Europe binds vendors instead, as the Cyber Resilience Act's 24-hour vulnerability warning shows. Four figures from GOV.UK, the PSTI Act 2022 and Broadband Breakfast show the gap.

UK Rule in Force So Far

29 months

Every UK sale since April 2024

FCC Money for the US Label's Administrator

$0

Runs on industry goodwill

Legal Duties on Each UK Device

3

Covered without reading anything

Top UK Fine as Share of Revenue

4%

Scales up for global brands

A fine pegged to worldwide turnover is too big for a global router brand to treat as a cost of selling in Britain, so the cheap answer is one firmware build for every market. You just can't tell from a US box which makers did it.

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Britain needed no sticker to make every router safer. Washington's sticker can't even pay the people meant to run it.

Does the UK ban default passwords on smart devices?

Yes, the UK has banned universal default passwords on consumer connected devices since 29 April 2024, requiring each product to ship with a unique password or make the buyer set one, under the Product Security and Telecommunications Infrastructure regime.

The table sets that law against the US label, read as a buyer standing in a store.

Dimension UK law vs US label What it means for you
💰 Cost of skipping UK Fines up to £10 million
US No penalty at all
❌ US makers risk nothing by opting out
⚖️ Who must comply UK Every maker selling there
US Only makers that apply
⚠️ In a US store, you vet each box
🔒 Password rule UK Unique or user-set, all models
US Same idea, labelled models
✅ Labelled gear meets the British bar
🛠 Who runs it UK A standing regulator, OPSS
US No lead for 115 days
❌ Oversight can lapse with no warning
🌍 Coverage UK The whole country
US State law in 2 of 50
⚠️ Your ZIP code sets your protection
🏁 Best suited for UK Any buyer, no homework
US Buyers who read every box
🏁 Law wins whenever a shopper is rushed

Read down the right-hand column: the label helps only buyers who already do the work. The first-row fine comes from the PSTI Act 2022; the 115-day gap is my arithmetic from the reported dates above.

California. and Oregon. 2020 State law, in force. United Kingdom. 2024 National law, in force. European Union. Dec 2027 Law, applies soon. US federal level. None Voluntary label only.

Outside California and Oregon, no US law guarantees that the next router you buy ships with a unique password. Dates come from each jurisdiction's own text: California SB-327, the UK PSTI regime and EU Regulation 2024/2847.

Do routers have to come with unique passwords?

Only in some places: in Britain since April 2024, in California and Oregon since 2020, and across the EU from December 2027, while a router sold in the other 48 US states can still legally share one factory password.

California's SB-327, operative since 1 January 2020 (as of 2020), demands a password "unique to each device manufactured" or one the user creates. Oregon passed a near-copy. The EU's Cyber Resilience Act, on EUR-Lex, requires a secure by default configuration once its main obligations apply on 11 December 2027. So the "too costly" objection collapses: the engineering exists, and the biggest US state has demanded it for years.

The second objection calls default passwords a niche consumer worry. CISA disagrees. In December 2023 (as of 2023) its Secure by Design alert urged makers to drop default passwords after attackers reached Unitronics controllers at US water facilities; CyberScoop reported their factory password was 1111, so one shared login opened every identical unit. The federal security agency called it a manufacturer failure in writing, then only asked nicely. As with post-quantum migration deadlines, guidance without teeth moves at the pace of the slowest vendor.

One grey area remains, and this is opinion: should a federal rule reach devices already in homes? I'd cover new sales only, because retroactive rules invite lawsuits that stall everything. Watch-outs meanwhile:

  • A Cyber Trust Mark helps, but its absence proves nothing.
  • An app-based setup can leave the local web login on its factory value.
  • Marketplace imports may follow no national rule.

Check these before the device goes on your network

  • Setup forces you to create your own admin password, or the label shows one unique to that unit.
  • The maker's site names a security-update end date for your model.
  • The maker publishes a way to report security bugs.
  • The login printed in the manual stops working after setup.

So here's the decision. If you're in the US, treat the label as a bonus and the password check above as the real test, and this week log in to your own router and replace any password printed in its manual. Then tell your representative that Britain already proved the rule costs makers almost nothing.

Thursday, October 1, 2026

Memory Safety Roadmap: The 1,000x Case

Here is the rule. Under the Product Security Bad Practices guidance from CISA and the FBI, a maker of software used in critical infrastructure that had no published memory safety roadmap by January 1, 2026 is, in the agencies' own word, "dangerous". The date came and went. Your firewall vendor, your hospital's imaging supplier, the firm behind your water utility's control panels: none of them owed you a thing when it passed.

Circuit board with a padlock on its memory chips, illustrating a memory safety roadmap

The flaw is in the rule. The same document says it "is non-binding" and "imposes no requirement", so the risk of a missing plan sits with you, the customer. It should be compulsory. And the standard objection, that leaving C and C++ is too slow and too costly, no longer survives the data.

Key Takeaways

Yes, a published plan to retire memory bugs should be compulsory, and buyers can enforce one through contracts today.

  • The federal date passed with no penalty, so the risk sits with the customer.
  • Memory-safe code cut Google's largest bug class without slowing releases.
  • Products near end of life are exempt, so ask for support end dates first.
  • Write a dated plan covering network-facing code into your next renewal.

Is CISA's memory safety guidance mandatory?

No, CISA's memory safety guidance is voluntary: the agencies call a missing roadmap dangerous for critical-infrastructure software, but attach no fine and no procurement ban, so a vendor that ignored the January 2026 date faces nothing.

Washington has stayed in that register. A June 2025 NSA and CISA information sheet on memory safe languages (Rust, Go and others that stop code touching memory it does not own) says the agencies "urge organizations to consider whether adopting MSLs is practical for their circumstances." That hands every vendor two exits, "consider" and "practical". A buyer waiting for a federal push is waiting for something the government has said, in writing, it will not do.

Other regulators have been less shy. Europe wrote vulnerability handling into law, down to the 24-hour exploited-vulnerability warning the Cyber Resilience Act demands. Even NIST put calendar years on its post-quantum migration deadlines. Memory safety, the older and better-understood problem, got an adjective.

Is Rust really safer than C++?

Yes, by a margin that ends the argument. A November 2025 Google report, Rust in Android, found its roughly 5 million lines of Rust running at about 0.2 memory-safety vulnerabilities per million lines, against roughly 1,000 in its C and C++, a reduction Google puts at more than 1,000x. That kills the excuse that safer languages just move bugs elsewhere.

But the objection was always about cost: rewriting slows teams, and ship dates pay salaries. Four numbers test that. Google's Android data supplies two, measured on changes of comparable size. MITRE's CWE Top 25, released in December 2025, supplies a count of memory errors among the most dangerous weaknesses. The calendar supplies the last.

Days Past the Federal Date

273 days

Every one at your risk

Code Review Time Saved

25% less

Reviewer hours handed back

Memory Flaws in CWE Top 25

6 of 25

Worst weaknesses a plan retires

Rollback Rate, Rust vs C++

4x lower

Fewer broken releases to undo

Show the rollback figure to a sceptical finance director. A rollback is a release pulled after shipping, usually an outage and a lost weekend. Fewer of those means the cost objection runs backwards.

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The safer code also broke four times less often. Speed was the excuse, and Google's own releases retired it.

With no regulator compelling a plan, your contract is the only lever left.

What a required memory safety roadmap changes for buyers

Requiring the plan turns a vendor's vague intention into a dated, auditable commitment that covers its riskiest code first, which gives a buyer something to enforce at renewal instead of a hope.

Dimension Optional vs Required What it means for you
💰 Cost of skipping Optional nothing under federal rules
Required a breach you can enforce
❌ The vendor's risk lands on you
⏱ Deadline Optional 1 Jan 2026, already missed
Required a date you set and enforce
⚠️ Only your contract makes it bite
📊 Flaws per 100k Optional about 100 in C or C++
Required about 0.02 in new Rust
✅ New code stops adding the top bug class
🔒 Fix order Optional whatever the vendor picks
Required network, crypto code first
✅ Your exposed surface is fixed soonest
⚖️ Legacy escape Optional every product, forever
Required support ends before 2030
⚠️ Ask each vendor for its end date
🛠 Proof on file Optional a promise on a sales call
Required public, like F5's Feb 2026
✅ You can audit it against releases
🏁 Best suited for Optional tools you retire this decade
Required anything facing the internet
🏁 Default to required for edge vendors

The flaw-rate row is my arithmetic, not Google's: Android's measured densities scaled to a 100,000-line component. At those rates a new C++ service carries latent memory flaws in triple figures, and the Rust version most likely none.

Industry norm Google plots · about 70%. Memory bugs. Android in 2025, after Rust · under 20%. Memory bugs.

This settles whether a plan is worth demanding: following one moved memory bugs from most of the problem to under a fifth of it. Source: Google's Rust in Android report, whose chart marks the upper bar as the industry norm.

Where a compulsory roadmap gets hard

A compulsory plan gets hard in two places: products close to retirement, which the guidance already exempts, and vendors who publish a roadmap with no dates in it, which satisfies the letter while changing nothing.

Do software makers have to stop using C and C++ by 2026?

No. The CISA and FBI guidance asks existing products for a plan, not a rewrite, and only calls new critical-infrastructure product lines in C or C++ dangerous where a memory-safe alternative exists. I'd go further than CISA, or at least put it more bluntly: a roadmap without a year beside each component is a brochure.

The unresolved question, in my opinion, is embedded firmware. A substation controller will not be rewritten, and a plan for it may mean little beyond the next model. Newer guidance shares the gap, such as the NSA's May 2026 advisory on MCP security for AI agents: sound advice, no teeth. Watch for:

  • Goals with no year per component.
  • Memory-safe claims covering only new features.
  • An end-of-support date just inside the exemption.
  • Sandboxing sold as a substitute, not a stopgap.

Check this against each vendor before your next renewal

  • It faces the internet or handles your keys.
  • Its support is not scheduled to end this decade.
  • Its newest features are still written in C or C++.
  • It cannot send a plan with a year per component.

If two of those are true, stop waiting for Washington. This week, email the vendor asking for its published plan and support end date, and tell procurement that renewal now depends on a dated commitment, cryptographic code first. Require it yourself, because nobody else will.